Centralised Registration – Board scales down DGST’s complicated procedure
The DG, Service Tax had issued an elaborate, complicated and impossible procedure for centralised registration. In DDT 141 on 01 07 2005, this column had pointed out that:-
The check list requires the applicant to give information on
1. Residential address of proprietors/partners/directors.
2. Proof of address of the registered premises.
3. Bank account numbers.
4. List of branches, offices or premises of the assessee along with the names of persons.
5. Details of the accounting systems adopted and the method to ensure that no transaction remains unaccounted.
6. An undertaking that information records and data will be made available within ten days to the audit team.
7. Separate lists of records maintained at the branches and the registered premises.
8. List of reports submitted by branch offices to the head office.
9. A recapitulation statement showing service wise quantum of service rendered.
10. Information on how Data/Information is transmitted from branches to head office.
11. Information as to whether recoveries are affected through Credit/Debit notes.
12. Whether penal interest is collected.
13. Branches wise series of invoices with a few sample copies of invoices
All this information is to be certified as correct by the Managing Director and the concerned Chartered Accountant. The field formations are to verify annually that the information is correct and valid. The DG does not clarify as to who should certify if there is no Chartered Accountant or MD. Maybe registration will be refused.
DDT is happy to report that better sense has prevailed and Board has issued instructions to over-rule the DGST and simplify the procedure. We are extremely happy to inform you that all the above requirements except sl. Nos. 2,4 and 11 have been removed from the list in the annexure to the application for registration. The DGST’s form had 22 items out of which the 11 items mentioned above have been removed.
DDT had further questioned,
And is there any time frame for the registration process to be completed? It takes about 15 days for a paper to reach from one section to another in a Commissionerate. When will the application reach the DG and come back? And when the department is talking so much about computerisation, why can’t the DG take the application online and give the registration within a few minutes?
DDT is happy to report that Board has fixed a time limit of seven days for the entire verification and another seven days for DG to verify if he wants.
One of our enlightened netizens had written in to say that if the DG’s instructions were to be complied, you would need a consultant just to get a registration. Board’s pruning the list by half would make things simpler.
DDT in all humility thanks the Board for its positive response. This is exactly how a tax administration should work, especially when overzealous DGs go overboard with their impossible prescriptions.
Unfortunately the clarifications are contained in a letter from the Board to the DG. This should have been a proper circular. Fortunately, the Board has not kept it a secret.
Finally it would be nice if Board can issue instructions to DGs of this world, especially of the service tax kind not to go round issuing instructions and prescribing forms. The DG, Service Tax seems to be acting in haste and regretting in leisure.
CBEC letter in F.No.354/106/2005-TRU dated 8.8.2005